Comments on the proposed orientation of the CFS study on THE ROLE OF SUSTAINABLE FISHERIES AND AQUACULTURE FOR FOOD SECURITY AND NUTRITION International Collective in Support of Fishworkers (ICSF) The orientation and scope of the study should be within the overarching framework of a human rights-based approach (HRBA) (as understood within the United Nations system) that recognizes the right to food as a fundamental right, and that has a particular focus on marginalized and vulnerable groups, including women. It is suggested that the questions asked need to be rephrased substantively and that note needs to be taken of the report on fisheries and food security presented by the UN Special Rapporteur on the Right to Food to the United Nations General Assembly in October 2012. Specific comments on each of the questions follow: 1. How can the implementation of the FAO “Code of Conduct “for Responsible Fisheries and Aquaculture” be further improved globally for sustainable aquatic resource management? Under Question 1, reference should be made to the FAO process underway of developing Guidelines on small-scale fisheries, a process that has significant significance for food and nutritional security. The SSF Guidelines are seen as complementing the Code of Conduct for Responsible Fisheries (CCRF) It should be noted that the CCRF does not have aquaculture in the title, though there is a section on aquaculture. 2. How will nations maintain the integrity of the resource base (the source of food) in the face of these pressures, and the livelihoods dependent on them? Question 2 should rather be: How will nations maintain the integrity of the resource base (the source of food) and the livelihoods, particularly of marginalized and vulnerable groups, dependent on them in the face of these pressures? Another key issue is the need for national and international administrations to develop national as well as regional plans and strategies for sustainability, based on an ecosystem approach and precautionary principles, ensuring public participation, especially of marginalized and vulnerable groups, and taking into account the role of fisheries and aquaculture in coastal and inland communities. With reference to an ecosystem approach, and in the context of the overall framework within which the study should be scoped, it needs to be mentioned that an ecosystem approach should be consistent with a human rights-based approach. 3. What are the key socioeconomic issues which affect the sustainability and development of fisheries and aquaculture? Question 3 should rather be: What are the key socioeconomic issues which affect the sustainability and development of fisheries and aquaculture, and how can these be addressed in such a way as to ensure that fisheries and aquaculture contribute optimally to food, nutritional and livelihood security? The sub questions could be: What mechanisms are needed in the responsible governance of fisheries and aquaculture to facilitate adopting a socially inclusive and environmentally sustainable approach, with fair and responsible tenure systems which secure the rights of local communities, and particularly of vulnerable and marginalized groups within them, to life and livelihood, whilst promoting food and nutritional security? What kind of fisheries management policies should be pursued to ensure equity and sustainability of resources? How can decent work and social protection (with obvious implications for food and nutritional security), including through ratification of relevant ILO Conventions, be ensured in fisheries and aquaculture? The effort should be to promote sustainable development (rather than stress on economic growth) that balances social, economic and environmental objectives, consistent with the Rio+20 Outcome document. 4. To what extent can contributions be made to policy development and have considerable impact on securing small-scale fisheries /artisanal fisheries in their fundamental rights and creating benefits, especially in terms of food security and poverty reduction? Question 4 may be rephrased as follows: To what extent can contributions be made to policy development to secure the fundamental rights of small-scale fishing communities, including workers (both men and women) engaged in all aspects of small-scale and artisanal fisheries and aquaculture, and to improve their circumstances, especially in terms of food security and poverty elimination. Again mention needs to be made of the FAO process underway to develop Guidelines on small-scale fisheries. It should be noted that current policies for privatizing common property fisheries and coastal area resources are designed to minimize or exclude the role of the State and to permit the market to play a key role (example, through trading of fishing quotas and aquaculture concessions). Such policies are consolidating the exclusion of small scale fisheries, indigenous coastal peoples and coastal communities, and are favouring the economic concentration and transnationalization of the national fisheries and aquaculture sectors. It should also be noted that apart from policy development, specific initiatives are needed to support small-scale capture and culture fisheries to secure their rights, including through supporting their better organization and representation in decision making processes. It also should be noted that small scale inland fisheries faces similar threats like small-scale coastal fisheries. 5. How can the gender specific needs and rights of women be protected through enforceable rights over land, water resources, credit and other related matters? Question 5 needs to be rephrased. A better formulation would be: How can the rights and interests of women working in the fisheries sector and of women of small scale fishing communities, be protected in all aspects of fisheries and aquaculture, taking note of the specific forms of discrimination facing them, including through facilitating their better organization and representation in decision making and through securing their rights to land and fisheries resources, credit and other productive resources and services? It should be noted that women do not face handicaps, but they face unequal rights and discrimination! 6. What continuous improvements in institutional capacities (both national and regional) is critical for the success of management and governance of sustainable fisheries and aquaculture? The scoping needs to specifically discuss the importance of supporting/ facilitating local institutions, applying a social relations analysis, given that social relations, in particular gender, class, age and ethnic relations are reflected in institutions. There is need to ensure that marginalized and vulnerable groups are not excluded, as this will also affect the success of management and governance of fisheries and aquaculture. The scoping also needs to highlight the importance of giving priority to and strengthening national scientific capacity, and research in aquatic biodiversity and marine ecosystems, giving equal importance to local and indigenous knowledge, given the deep crisis in many of the world’s fishery management systems and with several of the world’s fisheries overexploited. Key tools for the governance of sustainable fisheries and aquaculture are public scrutiny and transparency. Ways in which a binding political process that permits citizens organizations, coastal communities and indigenous people to access relevant information, and that allows them to participate effectively in defining policies and management measures in the fisheries and aquaculture sector, need to be explored 7. How sustainable aquaculture can be promoted for food security and nutrition, as well as livelihoods, into the longer term? Question 7 needs rephrasing along the lines: "What kinds of aquaculture are sustainable and with the potential to enhance food security and nutrition, as well as provide livelihoods, into the longer term, and how should/ could these be developed/ promoted?" The write-up should highlight the need to explore the role that myriad forms of integrated and low-input small-scale aquaculture play in contributing to food and nutritional security of rural and other populations. The focus in the current text is more on export-oriented intensive forms of aquaculture. Questions that need to be asked are whether such models are sustainable in the longer-term, given that they are based on the cultivation of exotic carnivorous species, government subsidies, technology packages (antibiotics, chemicals, genetic engineering), cheap labour, use of fishmeal, energy, and the intensive use of local natural resources such as water and other coastal resources. The socio-economic costs, including closing of off access to traditional fishing grounds and resources and implications for food and nutritional security, salinization/ degradation of groundwater, violence faced by communities etc., and violations of labour rights, also need to be explored. Local communities should be added to the question below as follows: How do we facilitate the development of integrated policies and management measures, which are effective and acceptable to both national and regional administrators AND LOCAL COMMUNITIES. 8. What policies are necessary for fair and improved trading? Question 8 needs to focus more on trade and food security, posing the question: What forms of trade promote food security and nutrition and contribute to human wellbeing and development, and how can these be developed effectively? The sub-question could be: Considering the factors that are affecting the fisheries trade, it is essential to analyse fish trade issues with a food and nutrition lens and provide policy options that promote trading systems that enhance, rather than undermine food security and nutrition. The analysis should focus particularly on small-scale fish producers and traders, with a particular attention for small scale women vendors and traders, and low-income consumers that are vulnerable from a food and nutrition perspective. 9. What would promote fish value chain development that supports food security and nutrition? Question 9 is better phrased as follows: How can the fish value chain be modified and improved to promote food and nutritional security, and to secure livelihoods, particularly of marginalized and vulnerable groups. The scoping needs to include a gender analysis of the fish value chain from a food and nutrition perspective.